Relating to the licensing and regulation of orthotists and prosthetists.

Contracts

• Employment Agreements: Revise offer letters for non-traditional candidates. Change "contingent on eligibility" to "contingent on final licensure." The discretionary nature of the new law removes the guarantee of licensure.
• Recruiter Agreements: Update terms with staffing agencies to include fee clawbacks if a candidate is denied licensure under the new discretionary standards.

Hiring/Training

• Pipeline Audit: Immediately screen all pending hires. Any candidate lacking standard academic/clinical credentials must submit their application to TDLR before September 1, 2025.
• Vetting Protocols: Cease offering unconditional employment to foreign-trained applicants or those relying on experience-based exemptions for start dates after September 1, until new agency rules are clarified.

Reporting & Record-Keeping

• Enhanced Documentation: Prepare for a shift in the burden of proof. Future exemption applications will likely require comprehensive portfolios (case logs, notarized affidavits, certified translations) rather than simple transcripts.
• Renewal Flags: Tag personnel files of employees licensed via exemption. The law prohibits the Commission from imposing exempted requirements during renewal, but you must verify this during internal audits.

Fees & Costs

• Administrative Costs: While statutory fees remain unchanged, anticipate increased legal and administrative costs to prepare the more complex, evidence-based exemption petitions required under the new discretionary standard.